L-2019-153, Exigent Technical Specification Amendment Request Supplemental RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG

Exigent Technical Specification Amendment Request Supplemental RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG

ML19206A658
Person / Time
Site:	Saint Lucie
Issue date:	07/25/2019
From:	Deboer D Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2019-153
Download: ML19206A658 (13)

Text

JUt 2 S 2019 L-2019-153 10 CFR 50.90 10 CFR 50.91 U.S. Nuclear Regulato1y Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 RE: St. Lucie Unit 1 Docket No. 50-335 Renewed Facility Operating Licenses DPR-67

Subject:

Exigent Technical Specification Amendment Request Supplemental RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG

Reference:

1. FPL Letter L-2019-147 dated July 19, 2019, "Exigent Technical Specification Amendment Request One-Time Allowed Outage Time Extension for Inoperable EDG." ADAMS Accession No. ML19200A283

2. NRC SER dated July 2, 2019, St. Lucie Plant, Unit Nos. 1 and 2 - Issuance of Amendment Nos. 247 and 199 Regarding Adoption of Risk-Informed Completion Times in Technical Specifications ADAMS Accession No. ML19113A099

3. FPL Letter L-2019-149 dated Jul 24, 2019, "Exigent Technical Specification Amendment Request RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG."

ADAMS Accession No. ML19205A407 In the Reference 1, FPL submitted an exigent request for an amendment to Facility Operating License No. DPR-67 for St. Lucie Unit 1 for Nuclear Regulatoiy Commission (NRC) approval.

FPL requested a change in the allowed outage time (AOT) for an inoperable emergency diesel generator (EDG). The current AOT allowed by Technical Specification (TS) 3/ 4.8.1 Action bis 14 days. FPL requested a one-time AOT extension for a total of 30 days.

On July 22, 2019, a teleconference was held between the NRC and FPL to discuss clarifications the Staff required to complete their review. FPL captured these requests and provided responses in Reference 3. In that response, FPL proposed suspending opposite train and unit EDG surveillances during the duration of the extended AOT. Based on the current 1B EDG repair schedule, there is no need to include the proposed surveillance suspensions at this time. This letter replaces the RAI response of Reference 3 in its entirety, eliminates the proposed EDG surveillance suspensions, and includes additional conforming changes to the compensatoiy measures to be implemented during the extended AOT duration. The TS changes proposed in this letter supersede those provided in References 1 and 3.

Note that although the proposed TS includes reference to the Risk Informed Completion Time program, the RICT requirements will remain under administrative hold pending full implementation of the RICT amendment of Reference 2.

Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2019-153 Page 2 The St. Lucie Onsite Review Group reviewed this submittal and concluded that operation of St.

Lucie Unit 1 in accordance with the proposed change will not endanger the health and safety of the public. The LAR justification and the exigent nature of the request remain unchanged. The responses to the RAis and revisions to the proposed TS changes do not affect the conclusions of the No Significant Hazards Consideration evaluation provided in Reference 1.

Additionally, in accordance with 10 CPR 50.91(b)(1), FPL is sending a copy of this letter and enclosure to the Florida Department of Health.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on Respectfully, lJ~/J~

DanDeBoer St. Lucie Nuclear Plant Site Director cc (Enclosure):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - St. Lucie Nuclear Plant NRC Project Manager - St. Lucie Nuclear Plant Director, Division of Radiological Health - Florida State Department of Health

L-2019-153 Attachment 1 Page 1of9 Defense in Dept h Qu estions NRC Question : What Compensatory Measures will St. Lucie implement during the extended allowed outage time (AOT)?

Response

FPL commits to implementing the following compensatory measures during the extended AOT:

1. The availability of alternate AC (AAC) power sources shall be checked every 8-12 hours (once per shift). If an AAC power source (e.g., a Unit 2 emergency diesel generator (EDG)) becomes unavailable at any time during extended AOT, the unavailable ACC unit will be returned to service in the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or Unit 1 will enter Mode 3 in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

2. No elective load threatening tests or maintenance activities will be allowed (e.g., component testing or maintenance of safety systems and important non safety equipment in the offsite power systems which can increase the likelihood of a plant transient (unit trip or loss of offsite power (LOOP))).

3. Any other preplanned maintenance will be rescheduled if severe weather conditions are anticipated .

4. The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the extended AOT.

From the St. Lucie procedure that implements the Configuration Risk Management Program, the following risk management actions (RMAs) are required while in the extended AOT:

• Conduct a plant fire protection walkdown ofthe areas that could impact EOG availability, offsite power availability, or the ability to use the SBO crosstie prior to entering the extended AOT.

• Perform a thermographic examination of high risk potential ignition sources in the Cable Spreading Room and the Control Room prior to entering the extended AOT.

• Restrict planned hot work in the Cable Spreading Room and Control Room during the extended AOT.

• Establish a continuous fire watch in the Cable Spreading Room when in the extended AOT.

• A Unit 2 EDG or the SBO crosstie shall only be removed from service for corrective maintenance required to ensure or restore operability of the equipment.

• Ensure that the relevant Guarded Equipment protected train measures have been taken.

• Validate availability of the minimum required fire detection and/or functional suppression systems in the identified important Fire Zones to be protected by plant procedures. If not met, then initiate fire watches in the affected zones in accordance with the Fire Protection Plan.

• Brief operators and fire team members on the significance of a fire in the identified important fire zones to be protected.

In addition to the above compensatory measures, existing plant procedures address monitoring weather conditions, and ensuring that actions are taken in the event adverse conditions are expected on-site. These actions are relevant during severe weather, tornado, or hurricane watches or warnings and include housekeeping, flooding, and high wind preparation considerations . Also, the procedure places the unit outside the EOG limiting condition of operat ion (LCO) applicability for operating units (i.e., MODES 1 or 2) by directing a shutdown based on the hurricane category. Upon issuance of a watch or warning which impacts the site, the following actions will be executed as required by the procedures for the watch or warning in

L-2019-153 Attachment 1 Page 2 of 9 effect:

• Perform site walk-downs and eliminate or secure missile hazards.

• Secure exterior cranes.

• Ensure Unit 1 and Unit 2 Reactor Auxiliary Building (RAB) exterior doors are closed.

• Ensure storm drain system capacity and the basin influent and discharge are clear of blockages.

• Pump down yard sumps, Unit 1 RAB sumps and Unit 2 RAB sumps.

• Verify RAB storage tanks have capacity for storm drainage.

• Deploy the portable diesel fire pump for dewatering.

• Perform a shiftly tail board with Operations Fire Team members to discuss the location of the fire equipment that has been relocated per plant procedures.

• Obtain meteorological forecasts and data from the National Hurricane Center in Miami, Florida at least once per six hours during either a Hurricane Watch or a Hurricane Warning and enter in the narrative log.

• Shutdown to at least HOT STANDBY (for Category 1, 2, or 3 hurricanes) or COLD SHUTDOWN (for Category 4 or 5 hurricanes) at least two hours prior to the onset of hurricane force winds at the site.

NRC Question: What are the Licensing Bases for SBO Timing?

Response

Section 15.10 of the Unit 2 UFSAR contains the SBO analysis. This analysis shows that St. Lucie Unit 2 can successfully endure a complete loss of AC power for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. However, it is expected that AC power would be restored within 30 minutes to one hour as a result of either one of the following corrective actions:

a. Offsite power is restored;

b. One or both of the St. Lucie Unit 2 diesel generators are started.

No credit is given for Unit 1 EDGs, but the DC coping capability is further enhanced by the ability to provide power to the one division of the Class lE distribution system from the available Unit 1 EDG. Even though the amount of power available to Unit 2 loads under a Station Blackout scenario (only one EDG operation on Unit

1) is limited by plant procedures as not to affect Unit 1 safe shutdown, it can be used to power selected loads, i.e., battery chargers, certain fans, etc.

Section 15.2.13 of the Unit 1 UFSAR contains the SBO analysis. As stated, Unit 1 is a four-hour SBO coping plant. At 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the DC coping period is assumed to end when the Unit 14160V lAB bus and Unit 2 4160V 2AB bus are manually connected and AC power is available to Unit 1, based on excess Unit 2 EDG capacity.

After 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, either offsite power is restored or one or both St. Lucie Unit 1 EDGs are started, thus terminating the event.

L-2019-153 Attachment 1 Page 3 of 9 NRC Question: What is the Licensing Basis for the required EDG capacity during SBO conditions?

Response

The Unit 1 and Unit 2 Section 3.1.5 requirements for EDG capability during SBO conditions is that in the unlikely event of a station blackout in one unit, i.e., total loss of AC power on-site and off-site, both units can be electrically connected, under administrative control, such that a diesel generator set from the non-blacked out unit is able to provide power to the minimum loads required to maintain both units in a hot standby condition.

NRC Question: Describe how the EDGs are protected from external flooding events .

Response :

Seismic Category I SSCs are protected from the effects of high water levels and wave runup through:

• Design to withstand such effects

• Positioning to preclude inoperability

• Housing within waterproof structures The plant grade around the structures is approximate EL+ 18.5 ft-PSL datum. Structures are flood protected up to EL +19.5 ft-PSL datum. Any exterior doors and penetrations below EL +19.5 ft-PSL datum which lead to areas containing safety-related equipment are watertight. All permanent door openings in the exterior walls of the RAB, fuel handling building, and diesel generator building are provided with either roll-up or swing-type doors for protection from rain, wind, and other atmospheric effects. Doors are furnished with continuous, adjustable rubber stripping at jambs, head, and floor to provide a positive weather-tight closure.

For Unit 1, the two diesel oil storage tank foundations have a top elevation of EL +22.2 ft-PSL datum and are surrounded by a 1-ft thick reinforced concrete retaining wall extending to EL +24.5 ft-PSL datum. The operating floor of the Unit 1 diesel generator building is at EL +22.67 ft-PSL datum. The Unit 1 diesel tank essentially has a concrete half-wall surrounding it which provides flood protection up to EL +24.5 ft-PSL datum.

For Unit 2, the diesel generator building floor and equipment are above EL +22 ft-PSL datum and no openings below EL +22.67 ft-PSL datum. The Diesel Oil Storage Tank Building have no openings below EL

+29.5 ft-PSL datum.

Flood hazards for St. Lucie were re-evaluated and submitted to the NRC via FPL letter L-2015-048 dated March 10, 2015. This letter documents that the probable maximum storm surge (PMSS) water level associated with hurricanes was determined to be at EL+18.3 ft-PSL datum, which is below the level for the Unit 1 and Unit 2 EOG buildings and equipment as shown above.

The St. Lucie flood hazards were re-evaluated for local intense precipitation events (LIP) and submitted to the NRC via FPL Letter L-2016-027 dated February 18, 2016. This evaluation documents that the local flood levels remain below the Unit 1 and 2 EOG operating floor and door levels. Therefore, LIP events have no adverse effects on EDG availability.

L-2019-153 Attachment 1 Page 4 of 9 PRA Related Questions NRC Question: The submittal states that some F&Os remain open. NRC requested a list of the open F&Os and an explanation as of why they do not impact the application

Response

Finding Description Resolution Impact CS-A3-01 4kV power and 12SVDC control cables The Component and Cable Selection Report Issue resolved for required to support the operation of the documents the equipment added to the fire the 4b model.

Containment Spray Pump were not PRA and provide a list of cables required to Resolution was identified. Fire PRA Plant Response model support the proper operation of credited purely and other Fire PRA support tasks are equipment. documentation.

adversely affected . Perform a comparison There is no impact Documentation added to show the function of the components identified on the MSO to this application.

of the cables that were selected to verify (multiple spurious operation) list against that all appropriate cables have been the Fire PRA components for which new selected and of a thorough review of the cable selection was performed (i.e.,

existing cable selection.

components not previously identified on the Appendix R safe shutdown equipment list). Verify that the cable selection for the common components supports all credited operati ons. Fire PRA Plant Response model and other Fire PRA support tasks are adversely affected CS-Bl-01 No evaluation was performed to verify A detailed review of the coordination Issue resolved for that the new components and cables analysis was performed including those the 4b model.

associated with the Fire PRA is bounded power supplies associated with Fire PRA Resolution was by the existing overcurrent coordination components. The Component and Cable purely analysis. The evaluation was not Selection Report documents breaker documentation.

completed at this time. coordination evaluations. There is no impact to this application.

Reference 21 and 22 have been added to support this claim. Documentation issues in the Breaker Coordination Calculation have been resolved.

SF-Al-03 The documented assessment/ review of Fire PRA Summary Notebook updated to Issue resolved for fires induced by seismic events fails to: address the items in the finding. the 4b model.

address common cause failures, review of Resolution was plant seismic response procedures, review purely of fire brigade training, associated documentation.

equipment storage and routes, and the There is no impact impact a seismic event would have on to this application .

them.

L-2019-153 Attachment 1 Page 5 of 9 NRC Question: Discuss the status of implementation items for this application and the impact to the application - [Very Early Warning Fire Detection System {VEWFDS) and whether or not its credited for this application]

Response

• VEWFDS is not credited in the Unit 1 Fire PRA. Consequently, there is no impact for this application.

• Note, VEWFDS is credited in the Unit 2 Fire PRA, which incorporates NU REG 2180. However, the Unit 2 PRA has no impact for this application .

NRC Question: RICT RAI discussed including the latest bounding plant-level seismic risk as part of RICT calculations. Why is it not needed for this application?

Response

Seismic risk at PSL is evaluated at plant-level with CDF and LERF of 3.49E-6 per year and 3.49E-07 per year, respectively. Consequently, incremental seismic risk is assumed to have no impact on the considered configuration. However, for the purpose of this submittal, if a seismic risk impact equivalent to the plant-level values is added to delta CDF/LERF, the overall risk impact due to the considered configuration is still below the RG 1.177 limits for one-time CT change NRC Question: NRC requested confirmation that FLEX is not credited

Response

FPL did not credit FLEX in the PRA evaluation for the extended EOG AOT. While FLEX equipment and strategies remain available and would be utilized if needed, they are not specifically identified in any compensatory actions.

NRC Question : NRC questioned what is credited or not in the ICCDP. It seems to be different from the estimate in the RICT LAR (14-day max in Enclosure 2).

Response

The FPL LAR for RICT utilized the draft Fire PRA model. The Fire PRA update made during implementation of the self-approval model included refinements that improved the overall risk. Examples include NU REG 2169 and 2178.

L-2019-153 Attachment 1 Page 6 of 9 NRC Question : Could you explain the model changes you listed in attachment 3.0, Section 3.0? Explain the changes associated with station blackout cross ties .

Response :

There were no model changes made to the baseline model to produce the application-specific model configuration . The baseline model and the application-specific model are the same PRA model but with different runs to consider the referenced EDG is out of service. The bulleted items represent the assumptions that were considered when calculated the configuration-specific results. The referenced methods associated with the station blackout cross ties are already credited in the model and assumed available when needed. It was also assumed that these cross ties are protected by compensation measures and thus no further treatment of their availability, or unavailability, were considered beyond those considered in the baseline calculation.

NRC Question : Provide the top 10 dominant CDF scenarios associat ed with internal events risk and fire risk.

Provide descriptive listing.

Answer:

Top dominant Cutsets in delta CDF in Internal Events*

1 SMALL LOCA IE, A-train MOV to containment sump (source for lA HPSI injection during long term) fails to open, AC breaker from 1B startup transformer to 4KV 1B2 bus fails to close, EDG 1B OOS in TM.

2 Stuck open SRV initiator occurred (similar to SLOCA), A-train MOV to containment sump (source for lA HPSI injection during long term) fails to open, AC breaker from 1B startup transformer to 4KV 1B2 bus fails to close, EDG lB OOS in TM .

3 LOSS OFF-SITE POWER (PLANT-CENTERED), EDG lA FTR, EDG lB OOS in TM, OPERATOR FAILS TO ALIGN BLACKOUT XTIE TO POWER UNIT 1 FROM UNIT 2, OPERATOR FAILS TO ALIGN NSR 4KV BUSES XTIE TO POWER UNIT 1 FROM UNIT 2, and OPERATOR FAILS TO CONTROL TD AFW PUMP DURING SBO & LODC.

4 LOSS OFF-SITE POWER (PLANT-CENTERED), EDG FO PUMP lA FAILS TO START, EDG 1B OOS in TM, OPERATOR FAILS TO ALIGN BLACKOUT XTIE TO POWER UNIT 1 FROM UNIT 2, OPERATOR FAILS TO ALIGN NSR 4KV BUSES XTIE TO POWER UNIT 1 FROM UNIT 2, and OPERATOR FAILS TO CONTROL TD AFW PUMP DURING SBO & LODC.

5 LOSS OFF-SITE POWER (PLANT-CENTERED), EDG lA FTS, EDG lB OOS in TM, OPERATOR FAILS TO ALIGN BLACKOUTXTIE TO POWER UNIT 1 FROM UNIT 2, OPERATOR FAILS TO ALIGN NSR 4KV BUSES XTIE TO POWER UNIT 1 FROM UNIT 2, and OPERATOR FAILS TO CONTROL TD AFW PUMP DURING SBO & LODC.

6 LOSS OF 4KV BUS 182 IE, 4 KV SWGR BUS 182 FAULT (1 YR EXPOSURE), EDG 1B OOS in TM, OPERATOR FAILS TO PROVIDE LONG TERM MAKEUP TO CST VIA TWST, OPERATOR FAILS TO PROVIDE SUCTION TO Ul AFW FROM U2 CST, OPERATOR FAILS TO USE THE DIESEL-DRIVEN FIRE PUMP TO REFILL THE CST, OPERATOR FAILS TO INITIATE ONCE-THROUGH-COOLING (OTC) using 2 PORVs.

7 LOSS OFF-SITE POWER (PLANT-CENTERED), EDG lA FTR, EDG 1B OOS in TM, OPERATOR FAILS TO ALIGN BLACKOUT XTIE TO POWER UNIT 1 FROM UNIT 2, OPERATOR FAILS TO ALIGN NSR 4KV BUSES XTIE TO POWER UNIT 1 FROM UNIT 2, and TURBINE-DRIVEN AFW PUMP lC FAILS

L-2019-153 Attachment 1 Page7of9 TO RUN.

8 LOSS OFF-SITE POWER (PLANT-CENTERED), EDG lA FTR, EDG lB OOS in TM, OPERATOR FAILS TO ALIGN BLACKOUT XTIE TO POWER UNIT 1 FROM UNIT 2, OPERATOR FAILS TO ALIGN NSR 4KV BUSES XTIE TO POWER UNIT 1 FROM UNIT 2, and AFW PUMP lC TRAIN UNAVAILABLE DUE TO TEST/MAINTENANCE.

9 LOSS OF 4KV BUS 1B2 IE, 4 KV SWGR BUS 1B2 FAULT (1 YR EXPOSURE), EDG 1B OOS in TM, CCF 20% OR MORE CRD/RODS FAIL TO INSERT.

10 SMALL LOCA IE, AC breaker from lB startup transformer to 4KV 1B2 bus fails to close, EDG 1B OOS in TM, HPSI PUMP lA FAILS TO RUN DURING INJECTION.

Too dominant Cutsets in delta CDF in Internal Fire*

1. Description 1 Main Control Board RTGB-103, [UlPAF] Plant Availability Factor Control Building Personnel Room Fire - Whole Room Burn, fail ctrl TD AFW pp during SBO &

LODC-FIRE, EDG 1B IN TEST OR MAINTENANCE, [UlPAF] Plant Availability Factor, FLAG - lAB 2 4KV BUS ALIGNED TO 1A3 4KV BUS Junction Box Bl12, EDG 1B IN TEST OR MAINTENANCE, [UlPAF] Plant Availability Factor, FLAG -

3 lAB 4KV BUS ALIGNED TO 1A3 4KV BUS 4 Cable Spreading Room - Hot Gas Layer Fire, [UlPAF] Plant Availability Factor Control Building Personnel Room Fire - Whole Room Burn, TURBINE-DRIVEN PUMP AFWlC FAILS TO RUN, EDG 1B IN TEST OR MAINTENANCE, [UlPAF] Plant Availability Factor, FLAG - lAB 5 4KV BUS ALIGNED TO 1A3 4KV BUS 6 PC-83 Severe Fire, [UlPAF] Plant Availability Factor 7 -0.5' Elevation Multi-Compartment Fire, [UlPAF] Plant Availability Factor 8 -0.5' Elevation Hot Gas Layer Fire. [UlPAF] Plant Availability Factor Control Building Personnel Room Fire - Whole Room Burn, fail ctrl TD AFW pp during SBO &

LODC-FIRE, EDG FO PUMP lA FAILS TO START, EDG lB IN TEST OR MAINTENANCE, [UlPAF]

9 Plant Availability Factor, Control Building Personnel Room Fire - Whole Room Burn, AFW PUMP lC TRAIN UNAVAILABLE DUE TO TEST/MAINTENANCE, EDG 1B IN TEST OR MAINTENANCE, [UlPAF] Plant Availability 10 Factor, FLAG - lAB 4KV BUS ALIGNED TO 1A3 4KV BUS

L-2019-153 Attachment 1 Page 8 of 9 NRC Question: Why is LERF 3 orders of magnitude lower than CDF?

Response :

Previously fire risk results were obtained using aggregate baseline cutsets resulting from quantifying all fire scenarios at high truncation . The LERF data input was obtained from different version of the model. The FRANX model was rerun and the new LERF numbers are in alignment and show a one order of magnitude lower than the CDF.

Internal Internal Fire Total Events Flood BASE CASE 3.SSE-06 7.58E-07 4.31E-05 lBEDG CDF OUT OF 3.62E-06 7.58E-07 7.12E-05 SERVICE LKDF 7.00E-08 1.62E-10 2.81E-05 BASE CASE 4.22E-07 4.41E-07 7.88E-06 lBEDG LERF OUT OF 4.33E-07 4.41E-07 1.45E-05 SERVICE

.6LERF 1.lOE-08 3.00E-11 6.59E-06 6.60E-06 Note: CDF and LERF results presented as "at-power" results for this onetime CT extension, instead of annualized like would be presented in a permanent plant change.

The ICCDP and ICLERP are presented in Table 4.1-2 is based on an overall 1B EOG CT of 30 days, including the 14 days associated with the current TS limit.

Table 4.1-3: ICCDP and ICLERP for Technical Specification Extension Based on Total Completion Time Per Day ICCDP ICLERP ICCDP I CLE RP 2.32E-06 5.43E-07 7.72E-08 1.SlE-08 NRC Question: NRC requested the external flooding screening impact to be provided .

Response

PER NRC Letter dated 12/15/17 (ML17325B360):

"The NRC staff concludes, based on the information provided by FPL, that adequate margin exists for the reevaluated LIP mechanism. The NRC staff agrees that the licensee's estimation of water accumulation is conservative. The staff also finds that the hydrostatic and hydrodynamic loading analysis performed on power block structures was done using appropriate engineering codes and standards and the resultant loads are relatively low and are not expected to negatively impact such structures. Therefore, the NRC staff concludes that the licensee has demonstrated that adequate and reliable passive features exist to provide flood

L-2019-153 Attachment 1 Page9of9 protection of key SSCs and maintain key safety functions as defined in Appendix B of NE/ 16- 05, Rev 1.

3.2.3 Overall Site Response The licensee does not rely on any personnel actions or new modifications to the plant in order to respond to the LIP event. As described above, the licensee's evaluation relied on passive existing flood protection features to demonstrate adequate flood protection; therefore, there is no need to review overall site response".

Based on this NRC letter, and the current plant design, no unique PRA model for external flooding scenarios is required to assess configuration risk for this application.

L-2019-153 Attachment 2 Page 1 of1 TS Mark Up

• • A one-time AOT extension for the inoperable 1B EOG allows 30 days to restore the EOG to OPERABLE status.

Compensatory Measure within FPL Letter L-2019-153 dated July 25, 2019 will remain in effect during the extended AOT period. This extension expires on August 14, 2019 at 0736 hours0.00852 days <br />0.204 hours <br />0.00122 weeks <br />2.80048e-4 months <br /> EDT.

3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE :

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and

b. Two separate and independent diesel generator sets each with :

1. Engine-mounted fuel tanks containing a minimum of 152 gallons of fuel,

2. A separate fuel storage system containing a minimum of 19,000 gallons of fuel, and

3. A separate fuel transfer pump.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION :

a. With one offsite circuit of 3.8.1.1 .a inoperable, except as provided in Action f.

below, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN .

b. With one diesel generator of 3.8.1.1.b inoperable, demonstrate the OPERABILITY of the A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; and if the EOG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the re OPERABLE EOG by performing Surveillance Requir . .1.1.2.a .4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, unless it can be confirmed tha se of the inoperable EDG does not exist on the remai in , estore the diesel generator to OPERABLE status within 14 days be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN. Additionally, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from the discovery of concurrent inoperability of required redundant feature(s)

(including the steam driven auxiliary feed pump in MODE 1, 2, and 3), declare required feature(s) supported by the inoperable EOG inoperable if its redundant required feature(s) is inoperable.

If the absence of any common-cause failure cannot be confirmed, this test shall be completed regardless of when the inoperable EOG is restored to OPERABILITY.

. LUCIE - UNIT 1 3/4 8-1 Amendment No. '100, ~ . ~. ++G,

'1-00. ~ . 234

L-2019-153 Attachment 3 Page 1of1 Word Processed TS 3/4 .8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A .C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE :

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and

b. Two separate and independent diesel generator sets each with :

1. Engine-mounted fuel tanks containing a minimum of 152 gallons of fuel ,

2. A separate fuel storage system containing a minimum of 19,000 gallons of fuel, and

3. A separate fuel transfer pump.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With one offsite circuit of 3.8.1.1.a inoperable, except as provided in Action f .

below, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1 .1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

b. With one diesel generator of 3.8.1.1.b inoperable, demonstrate the OPERABILITY of the A.C. sources by performing Surveillance Requirement 4.8.1.1 .1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; and if the EDG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.1.1 .2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, unless it can be confirmed that the cause of the inoperable EDG does not exist on the remaining EDG*; restore the diesel generator to OPERABLE status within 14 days** or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN . Additionally, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from the discovery of concurrent inoperability of required redundant feature(s)

(including the steam driven auxiliary feed pump in MODE 1, 2, and 3), declare required feature(s) supported by the inoperable EDG inoperable if its redundant required feature(s) is inoperable.

If the absence of any common-cause failure cannot be confirmed, this test shall be completed regardless of when the inoperable EOG is restored to OPERABILITY.

A one-time AOT extension for the inoperable 1B EOG allows 30 days to restore the EOG to OPERABLE status. Compensatory Measure within FPL Letter L-201 9-153 dated July 25, 2019 will rema in in effect during the extended AOT period. This extension expires on August 14, 2019 at 0736 hours0.00852 days <br />0.204 hours <br />0.00122 weeks <br />2.80048e-4 months <br /> EDT.

ST. LUCIE - UNIT 1 3/4 8-1 Amendment No. :\00, ~ . .+<l8, .:1-7G,

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